Intercompany Debt Transfers at Risk with New IRS Proposal

The whole issue of tax inversions, or companies relocating to offshore locations to gain better tax treatment has been front and center this presidential election. But a shot was heard around the USA when the Department of Treasury, on 4 April 2016, proposed new regulations when very few in the market were aware anything was under consideration.  Not only did these new regs address corporate inversions, but the proposal extended to intercompany debt.